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This content was subject to assurance by SGS Italia S.p.A. (14 March 2014).

Monitoring Code of Conduct violations

Violations of the Fiat S.p.A. Code of Conduct and Chrysler Group Integrity Code are essentially identified through:

periodic activities carried out by Internal Audit & Compliance

reports received in accordance with the Whistleblowing Procedures

reviews of standard operating procedures.

In 2013, Fiat S.p.A. Internal Audit & Compliance systematically verified the level of knowledge and the respect of the Code of Conduct throughout Fiat Group companies (excluding Chrysler Group). Operational audits which were expanded in 2012 to include assessment of ethical issues with particular reference to human rights, business ethics, conflict of interest, corruption and discrimination issues, have been further integrated with the Human Rights risk assessment based on the UN Ruggie Framework Guiding Principles.

During 2013, 264 cases of actual violations -received both internally and externally- of the Fiat S.p.A. Code of Conduct were reported. As a consequence of Code violations, 264 employees were subject to disciplinary actions, while 6 reports received through the Whistleblowing Procedure led to the introduction of improvements to the Internal Control System, such as the review of pertinent policies and procedures.

For all Code violations, the disciplinary measures taken were commensurate with the seriousness of the case and complied with local legislation. The relevant corporate departments were notified of the violations, irrespective of whether criminal charges were made by the authorities.

The principal types of violation verified in 2013 included inappropriate conduct by employees such as absenteeism, inadequate and unethical behavior and misuse of company assets. Cases of violations of the Code of Conduct involving discrimination were not assessed.